The Council on Governmental Relations (COGR), representing 190 member institutions, submitted a letter to Mr. Gilbert Tran of the Office of Federal Financial Management to address concerns regarding the 2020 Compliance Supplement (2 CFR Part 200, Subpart F, Appendix XI). The letter acknowledges appreciation for the office’s efforts but urges that audit requirements and related guidance concerning the novel coronavirus (COVID-19) be deferred to the 2021 Compliance Supplement, given the unprecedented challenges and unique activities institutions faced during the national emergency. COGR argues that standard audit procedures would not be appropriate for FY2020 in light of these extraordinary circumstances and requests that FY2020 audit reports exclude COVID-19-related activities.
Additionally, COGR reiterates the need for clearer definitions in compliance areas, specifically proposing that “paid” be defined as costs entered into an entity’s accounts payable system, aligning with existing regulations and aiming to improve audit clarity and timeliness. The letter also notes ongoing confusion in the section on procurement and suspension and debarment, encouraging continued efforts toward clearer language in the upcoming compliance supplements. Finally, COGR seeks clarification on why the Research and Development Cluster is permitted an additional compliance requirement compared to other clusters, as outlined in recent mandates to limit audit requirements. The correspondence concludes with expressions of willingness to collaborate further on these matters.
